Commitment Policy

Star Capital SGR S.p.A. has not adopted a Commitment Policy pursuant to Article 124-quinquies of the TUF, as the Management Regulations of the Funds currently under management, in principle, exclude investments in companies with shares admitted to trading on an Italian regulated market or from another Member State of the European Union.

The investments allowed in these companies are subject to a series of well-defined limitations and cases. Furthermore, it should be noted that on the date of publication referred to in this announcement, Star Capital SGR S.p.A. does not have in the portfolios of UCITS under management companies with shares admitted to trading on a regulated market in Italy or in another member state of the European Union.

It will be the SGR's responsibility to draw up and publish an Commitment Policy should the conditions arise in the future (eg establishment of UCIs with a focus on companies listed on regulated markets or amendments to the Management Regulations of UCITS in place regarding investment in companies listed on regulated markets).